Laurence Bambino

Laurence Bambino

Shearman & Sterling LLP

Contact  |  View Bio  |  RSS

Latest Publications

Share:

Proposed Regulations on Related-Party Debt Instruments Would Result in Dramatic Adverse Tax Consequences

On April 4, 2016, the US Department of the Treasury and the Internal Revenue Service proposed regulations under section 385 of the Internal Revenue Code that would recharacterize certain related-party debt instruments, in...more

6/3/2016 - Debt Debt Securities Internal Revenue Code (IRC) Proposed Regulation Related Parties

Treasury and IRS Issue Regulations on Inversions and Earnings Stripping

On April 4, 2016, the Treasury Department and the IRS issued temporary regulations under Section 7874 on inversion transactions that added some new restrictions and implemented provisions previewed in two prior IRS notices...more

4/15/2016 - Anti-Inversion Regulations Controlled Foreign Corporations Debt Securities IRS U.S. Treasury

Treasury and IRS Issue Additional Inversion Notice

The Treasury Department and the IRS released Notice 2015-79 (the “2015 Notice”) on November 19th to further limit expatriation transactions and to supplement the anti-inversion guidance issued by Treasury and the IRS on...more

11/24/2015 - Corporate Restructuring Foreign Corporations Inversion IRS U.S. Treasury

Final Regulations Under Section 871(m) Clarify Withholding Tax Rules for Equity-Linked Derivatives, Yet Many Challenges Remain

On September 17, 2015, the Treasury Department and the Internal Revenue Service (the “IRS”) issued new temporary and final regulations under section 871(m) of the Internal Revenue Code regarding the imposition of US federal...more

10/14/2015 - Corporate Taxes Derivatives Dividends Equity Securities Equivalency Determinations Final Rules Foreign Equivalency Determination Foreign Nationals HIRE Act ISDA Tax Treaty U.S. Treasury Withholding Tax

IRS Issues Final Regulations on F Reorganizations

In September 2015, the Treasury Department and the IRS issued final regulations (T.D. 9739) that provide guidance with respect to the qualification of a transaction as a reorganization under Section 368(a)(1)(F) (an “F”...more

10/14/2015 - Corporate Conversions Corporate Taxes Final Rules IRS Liquidation Mergers Reorganizations Shareholders Transfer of Assets U.S. Treasury

The Treasury and the IRS Issue Spin-Off Revenue Procedure and Notice Announcing No-Rule Areas That Are Under Study

On September 14th, the IRS released Rev. Proc. 2015 43 (the “Rev. Proc.”) announcing new “no-rule” areas with respect to spin offs involving substantial amounts of investment assets, small amounts of active trade or business...more

9/17/2015 - IRS Real Estate Investments REIT Revenue Procedure 2015-27 Revenue Procedure 2015-28 Spinoffs U.S. Treasury

Treasury and IRS Issue Inversion Notice

The Treasury Department and the IRS released Notice 2014-52 (the “Notice”) on September 22nd to limit expatriation transactions. The Notice states that Treasury will issue regulations intended to limit the tax benefits of...more

9/25/2014 - Corporate Taxes International Tax Issues Inversion IRS Tax Evasion U.S. Treasury

First Circuit Rejects Talley and Allows a Business Expense Deduction for Settlement Payments Made Under the False Claims Act

On August 13, 2014, the United States Circuit Court for the First Circuit rejected the United States’ request to deny Fresenius Medical Care Holdings Inc. from deducting a portion of a settlement payment to settle civil...more

8/19/2014 - Compensatory Damages False Claims Act (FCA) Fresenius Settlement Tax Refunds

New Proposed Regulations Under Section 871(m) Adopt a Single Factor Test but Delay Effective Date Until 2016

On December 4, 2013, the Treasury Department and the Internal Revenue Service (the “IRS”) released new final and proposed regulations under section 871(m) of the Internal Revenue Code regarding the imposition of US federal...more

12/9/2013 - Delays Financial Regulatory Reform Income Taxes IRS Swaps U.S. Treasury

Timeline for Initial FATCA Implementation Extended

The Treasury Department (“Treasury”) and the Internal Revenue Service (the “IRS”) announced on July 12, 2013 a general six-month extension to the timeline for initial implementation of the Foreign Account Tax Compliance Act...more

7/16/2013 - Delays FATCA FFI Foreign Banks IGAs IRS U.S. Treasury

US District Court Rejects Talley and Permits a Business Expense Deduction for Part of Double Damages Payment Under the False...

In a taxpayer-favorable decision earlier this month, the US District Court for the District of Massachusetts, following a jury verdict, entered judgment for a corporation in a tax refund suit permitting a business deduction...more

5/21/2013 - Business Taxes Civil Monetary Penalty Compensatory Damages Corporate Taxes False Claims Act (FCA) Punitive Damages Tax Deductions Tax Refunds

11 Results
|
View per page
Page: of 1

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:

Sign up to create your digest using LinkedIn*

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.

Already signed up? Log in here

*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.
×